Hydrochlorofluorocarbon Refrigerant Mixture Low Global Warming Potential
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 2903799030 | 38.7% | CN | US | Official Doc |
| 3827310000 | 38.7% | CN | US | Official Doc |
| 3827320000 | 38.7% | CN | US | Official Doc |
| 3824995500 | 38.7% | CN | US | Official Doc |
| 3824994900 | 41.5% | CN | US | Official Doc |
AI Analysis
❄️ Hydrochlorofluorocarbon (HCFC) Refrigerant Mixture | Low Global Warming Potential (GWP)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Customs Strategy 📌 I. Product Definition & Classification: Do You Really Understand "HCFCs"?
Hydrochlorofluorocarbons (HCFCs) are transitional substitutes for Chlorofluorocarbons (CFCs). As refrigerant mixtures with specific GWP characteristics, their classification depends heavily on whether they are raw chemical mixtures, specific applications, or derived from specific hydrocarbon sources.
In international trade, HCFC refrigerants are typically classified under two main chapters: 1. Chapter 29 (Organic Chemicals): If viewed primarily as halogenated derivatives of hydrocarbons. 2. Chapter 38 (Miscellaneous Chemical Products): If viewed as mixtures, preparations, or industrial chemicals not specifically named elsewhere.
⚠️ Key Distinction Point: - If the product is explicitly a "Halogenated Derivative of Hydrocarbons" (raw chemical structure focus) → Often falls under Chapter 29. - If the product is a "Mixture/Preparation of Halogenated Hydrocarbons" (industrial application focus) → Often falls under Chapter 38. - Crucial Note: Regardless of GWP "Low" claims, HCFCs are still regulated substances. The physical and chemical nature (halogenated) dictates the HS code, not just the marketing term "Low GWP."
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)
| HS Code | Product Description | Applicable Scenario | Basis for Classification |
|---|---|---|---|
2903.79.90.30 |
Halogenated derivatives of hydrocarbons (Other) | General HCFC mixture, low toxicity refrigerant blend | ✅ Fits "Halogenated Derivative"兜底 (Catch-all) category for organic chemicals. |
3827.31.00.00 |
Refrigerants containing halogenated derivatives of methane, ethane, or propane (HCFCs) | Product name explicitly contains HCFCs; specific material match | ✅ Direct Match: Specifically targets HCFCs (Halogenated derivatives of CH4, C2H6, C3H8). |
3827.32.00.00 |
Other refrigerants, not containing CFCs | Explicitly HCFC-based, CFC-free mixture | ✅ Application Specific: Matches "Refrigerant" function + "No CFCs" material constraint. |
3824.99.55.00 |
Halogenated hydrocarbon mixtures (Other) | HCFC viewed as a generic halogenated hydrocarbon mixture | ✅ Chemical Nature: Focuses on "Halogenated Hydrocarbon" composition. |
3824.99.49.00 |
Mixtures of hydrocarbons from petroleum/coal gas | HCFC as a mixture derived from petrochemical sources | ✅ Source-Based: Focuses on origin (petroleum/natural gas derivatives) and mixture status. |
🔍 Key Reminder: -
3827.31.00.00and3827.32.00.00are the most precise for Refrigerants. -2903.79.90.30is a common fallback for HCFCs if not specifically categorized as a "rechargeable refrigerant" in Chapter 38, but Chapter 38 is generally preferred for commercial refrigerant products. -3824.99codes are broader "Miscellaneous Chemical" categories; use only if specific refrigerant codes do not apply to the exact formulation.
💰 III. 2026 Latest Tariff Rate Details (Including Additional Duties)
✅ Applicable Country: United States (US) ✅ Origin: China (CN) ✅ Effective Time: Current rates apply as of 2026
🎯 1. Codes with 38.7% Total Tax (2903.79.90.30, 3827.31.00.00, 3827.32.00.00, 3824.99.55.00)
| Item | Content |
|---|---|
| Base Tariff | 3.7% (ad valorem) |
| Section 301 Additional Duty | +25.0% |
| Section 122 Additional Duty | +10.0% |
| Total Effective Tax Rate | 38.7% |
| Tax Calculation | CIF Value × 38.7% |
| De Minimis Exemption | ❌ NOT Eligible (deny_de_minimis) |
| Legal Basis Path | USITC:2903.79.90.30/3827.31.00.00/3827.32.00.00/3824.99.55.00 → SECTION301:25% → SECTION122:10% |
📌 Explanation: - "Base 3.7%": Standard MFN tariff for these chemical/refrigerant categories. - "Section 301 25%": Additional tariff imposed on Chinese goods under Trade Act of 1974 Section 301. - "Section 122 10%": Additional tariff under Section 122 of the Trade Act of 1974 (National Security/Supply Chain). - Total 38.7%: High impact on cost. Must be factored into pricing strategies.
🎯 2. Code with 41.5% Total Tax (3824.99.49.00)
| Item | Content |
|---|---|
| Base Tariff | 6.5% (ad valorem) |
| Section 301 Additional Duty | +25.0% |
| Section 122 Additional Duty | +10.0% |
| Total Effective Tax Rate | 41.5% |
| Tax Calculation | CIF Value × 41.5% |
| De Minimis Exemption | ❌ NOT Eligible (deny_de_minimis) |
| Legal Basis Path | USITC:3824.99.49.00 → SECTION301:25% → SECTION122:10% |
📌 Note: - This code has a higher base rate (6.5%) compared to others (3.7%). - Even with the same additional duties, the total cost is higher. - Avoid this classification unless absolutely necessary; prefer
3824.99.55.00(38.7%) if it fits the chemical description.
🛠️ IV. Customs Clearance Practical Advice (实战避坑指南)
✅ 1. Documentation Checklist (No Omissions)
| Document | Required | Explanation |
|---|---|---|
| ✅ Safety Data Sheet (SDS) | ✔️ | Critical. Must confirm HCFC composition, GWP, and hazard classification. |
| ✅ Certificate of Composition | ✔️ | Detailed breakdown of HCFC types (e.g., R-22, R-123, etc.) and percentages. |
| ✅ Commercial Invoice | ✔️ | Must clearly state "Hydrochlorofluorocarbon Refrigerant Mixture" and HS Code. |
| ✅ Packing List | ✔️ | Specify net weight/gross weight. Ensure cylinders are UN-rated for transport. |
| ✅ EPA Approval / TSCA Certification | ✔️ | Mandatory for US. Proof that the substance is registered with the EPA. |
| ✅ Non-CFC Declaration | ✔️ | Explicitly state that the product contains no Chlorofluorocarbons (CFCs). |
| ✅ Dangerous Goods Declaration | ✔️ | If applicable for shipping (though many HCFCs are non-flammable, pressure vessel rules apply). |
✅ 2. Declaration Strategy (Key Tips)
🔥 "Name Specific, Composition Clear, EPA First, Tariff Lower!"
| Scenario | Correct Declaration | Incorrect Approach |
|---|---|---|
| Standard Refrigerant Blend | Use 3827.31.00.00 or 3827.32.00.00 |
Declaring as "General Chemical" → Risk of misclassification penalty. |
| HCFC Mixture (No CFCs) | Emphasize "HCFC" and "CFC-Free" in description | Omitting "CFC-Free" → May trigger additional regulatory scrutiny. |
| Low GWP Claim | Include GWP value in spec sheet | Using "Low GWP" as the primary descriptor → Customs looks at chemical structure, not marketing. |
| Raw Chemical Mix | Consider 2903.79.90.30 if not for direct refrigeration use |
Declaring as "Refrigerant" if used for industrial cleaning → Misclassification. |
✅ 3. Special Cases & Handling
| Situation | Handling Advice |
|---|---|
| OEM Private Label | Provide brand authorization + same SDS. HS code remains the same. |
| Mixed Packages (Refrigerant + Cylinder) | Declare the refrigerant as the primary good. Cylinders may be separate or included, but refrigerant dominates classification. |
| Transshipment via 3rd Country | Ensure origin certificates are clear. Section 301/122 duties still apply if origin is China. |
| EPA Compliance | Failure to provide EPA compliance documentation can lead to seizure. Ensure the product is on the EPA's Significant New Alternatives Policy (SNAP) list if required. |
🌍 V. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Key Requirements | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3827.31.00.00 or 3827.32.00.00 |
38.7% | EPA Approval, SDS, TSCA | High duties due to 301 & 122. |
| 🇨🇳 China | 3827.31.00.00 |
~3-6% | CIQ, Chemical Import License | Lower duties, stricter environmental regulations on HCFC use. |
| 🇪🇺 EU | 3824.99 or 2903.79 |
0-6.5% (varies) | REACH Registration, F-Gas Regulation | F-Gas Regulation is critical. HCFCs are being phased out/restricted. |
| 🇯🇵 Japan | 3824.99 or 2903.79 |
0-5% | JIS Standard, Safety Act | Strict safety standards for pressure vessels. |
📌 Conclusion: - USA is the highest cost market due to the 38.7% total tariff. - EU is the most regulated market regarding the use of HCFCs (F-Gas Regulation). Even if duties are low, regulatory barriers are high. - Always verify EPA (US) or ECHA/REACH (EU) compliance before shipping.
📌 VI. Common Errors & Pitfalls (Lessons Learned)
❌ Error 1: Declaring as "General Chemical" without specifying HCFC composition. 👉 Consequence: Customs may reject the entry, demand additional testing, or misclassify it, leading to delays and penalties.
❌ Error 2: Ignoring EPA/TSCA compliance. 👉 Consequence: Seizure of goods at US border. HCFCs are strictly regulated.
❌ Error 3: Using 3824.99.49.00 when 3824.99.55.00 applies.
👉 Consequence: Paying 2.8% extra (41.5% vs 38.7%) unnecessarily.
❌ Error 4: Claiming "Low GWP" implies duty-free status. 👉 Consequence: False. GWP is an environmental metric, not a trade preference criterion. Duties apply based on HS Code.
✅ Correct Practice:
"Hydrochlorofluorocarbon (HCFC) Refrigerant Mixture, R-XXXX Blend, Non-Flammable, EPA Registered, CAS Numbers [List], Net Weight [X] kg."
🎯 VII. Conclusion: Precise Classification, Smooth Clearance, Cost Control!
🎯 Remember the Mantra:
🔹 "HCFC is Halogenated, Chapter 38 is Key." 🔹 "38.7% is the Baseline, 122+301 Add Up." 🔹 "EPA First, Then Customs, No Excuses."
📌 Pro Tip: - If your product is a blending of HFCs (Hydrofluorocarbons) instead of HCFCs, the HS code and tariff may differ. Ensure your SDS clearly distinguishes between HCFCs and HFCs. - Consider applying for an Advance Ruling from US Customs and Border Protection (CBP) if the product is a novel mixture, to avoid post-entry audits.
📣 Immediate Action:
📞 Consult with a Licensed Customs Broker + Provide SDS + Verify EPA Compliance 🚀 Ensure Your Refrigerant, Clears US Borders Efficiently, and Maximizes Profit Margins!
✨ Professional Customs Clearance Starts with Accurate Classification! 💼 Every Percent of Tax Saved is Pure Profit!
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About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) — More specific grouping within the chapter
- Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) — Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate — The standard duty rate applied to WTO members
- General rate — Applied to countries without trade agreements
- Trade remedy duties — Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.